In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking about the waste disposal requirements for banks. See what the experts had to say.
Q: We have multiple bank branches in many states and the facility managers want to transport the branch’s universal waste to a central location for collection and then ultimately disposal. May they do that or does the waste need to remain at each location?
You can self-transport your universal waste (UW) to another location to consolidate it with the UW from other branches, provided you comply with the appropriate UW rules which address UW transporter and UW handler responsibilities. (Note that the states in which you have branches and the central location collection site may have UW requirements that are in addition to—or slight variations from—the federal requirements that are discussed in this answer.)
UW transporter responsibilities. As the generator of the UW that is self-transporting the waste, you would be considered a UW transporter and would have to comply with the UW transporter regulations of 40 CFR 273, Subpart D (40 CFR 273.50 to 273.56). In addition, although off-site shipments of UW do not require a manifest, the self-transporter would have to comply with U.S. Department of Transportation (DOT) requirements, if applicable. In other words, if the UW you are transporting meets the definition of “hazardous material” at 49 CFR 171.8, you would need to comply with the DOT regulations at 49 CFR 171 through 180. These DOT regulations would require you to package, label, mark and placard the hazardous material shipment, and prepare the proper shipping papers. Therefore, you will need to make a determination as to whether your UW is considered a DOT hazardous material in order to know whether the DOT requirements apply.
UW handler responsibilities. The branch locations shipping the UW as well as the location that is accepting the UW for consolidation would be considered UW handlers that would need to comply with the applicable UW regulations for either small quantity handlers (SQHUW) or large quantity handlers (LQHUW). SQHUWs and LQHUWs can receive UW from other UW handlers. Bear in mind that if the branches and/or the consolidation location collects more than or equal to 5,000 kilograms (11,023 pounds) of the total accumulation of universal waste at any one given time (calculated collectively and not by UW type), it will be considered an LQHUW.